CC Docket No. 95-72 End User Common Line
Adopted: May 24, 1995 Released: May 30, 1995
Comment Date: June 29, 1995
Reply Date: July 14, 1995
By the Commission:
A. ISDN and Other Derived Channel Technology and Services
3. Currently, LECs' offer two basic types of ISDN service.(n6) Basic Rate Interface (BRI) Service allows a subscriber to obtain two voice-grade-equivalent channels and a signalling/data channel over an ordinary local loop, which is generally provided over a single twisted pair of copper wires.(n7) Primary Rate Interface (PRI) Service allows subscribers to obtain 23 voice-gradeequivalent channels and one data channel over a single T-1 facility with two pairs of twisted copper wires.(n8)
4. A small business or residential customer with BRI
can use voice service, access a database service, and send
a facsimile, all at the same time, over a single local
loop consisting of a twisted copper pair. Standard local
exchange service permits only one of these activities at
a time. BRI also permits customers to transmit and retrieve
data at higher speeds than are currently possible using
a standard analog local loop and a modem. PRI and other
derived channel services afford larger business customers
the advantages of digital service, including higher speed
data transmission and greater accuracy. In addition, the
use of ISDN and other services providing customers with
multiple voice-grade-equivalent channels over a single
facility (derived channels) can avoid or reduce the need
for new cabling, and thus conserve space in existing conduit
or intra-building cable vaults.
5. There are services in addition to ISDN that use derived channel technology to provide multiple channels over a single facility. For example, NYNEX provides FLEXPATH service, which provides a customer with 24 digital voice-grade-equivalent trunk channels over a T-1 facility between a suitably equipped central office and a digital PBX.(n9) PBX Conversion Service, another NYNEX offering, provides digital trunking capability, with up to 24 trunk access lines, between a customer's digital PBX and an analog-to-digital interface located at the central office switch.(n10) Other LECs also offer digital T-1 service with 24 voice-grade equivalent channels. NYNEX's Data Over Voice service provides customers with a voice grade channel and a data channel over a single copper pair. The LECs also use derived channel technologies within their networks to provide customers with individual local loops, as opposed to BRI or PRI ISDN for example. In such situations, the end user would not be aware that the LEC was using this technology to provide their localloop.(n11)
8. The SLC rate structure is designed to recover a
greater proportion of local loop costs from multiline business
customers than from residential and single line business
customers. Multiline business customers pay the full
interstate assignment of local loop costs up to $6.00 per
month. In contrast, residential and single line business
customers pay a SLC of no more than $3.50 per month, which
is, in most cases, significantly below the full interstate
assignment of local loop costs.
9. As the recovery of interstate loop costs through SLCs increased, the interstate Common Line loop costs that remained to be recovered through CCL rates paid by the IXCs decreased. Thisresulted in substantial reductions in CCL rates. The Commission required AT&T to flow the reductions in per minute interstate CCL charges through to consumers in the form of reduced interstate toll rates.(n19) Basic interstate toll rates decreased approximately 34% between 1984 and the end of 1992, much of this due to the shift in the recovery of common line costs from CCL rates to SLCs and the resulting stimulation in demand.(n20)
11. The Common Carrier Bureau rejected the Transmittal based on a finding that it did not comply with the rule governing assessment of SLCs.(n22) In doing so, the Bureau relied on the Part36, Jurisdictional Separations, definition of a subscriber line as a "communication channel between a telephone station, PBX [Private Branch Exchange], or TWX (Teletypewriter Exchange Service) station and the central office,"(n23) and the Part 36 definition of a channel as an "electrical path suitable for the transmission of communications between two or more points."(n24) In the provision of derived channel services, the Bureau concluded that NYNEX was providing up to 24 electrical paths suitable for the transmission of communications even though the channels were provided over a single facility.(n25)
12. In a recent Order, the Commission affirmed the Bureau's conclusion that Section 69.104 of the rules requires assessment of a SLC for each derived channel.(n26) At the same time, the Commission recognized that many of the comments filed in that proceeding raised policy issues best considered in the context of a rulemaking proceeding.(n27)
14. These developments tend to bring pressure to bear
on support flows in the current access charge structure.(n33)
LEC ratesthat significantly exceed cost will tend to attract
new entrants who may be able to offer service at lower
rates. As a result, it may be necessary to reduce support
flows that are not specifically tailored to produce social
17. This rulemaking proceeding gives the Commission an
opportunity to reexamine existing rules, and make changes
in light of new technologies and services. We must be
careful to avoid erecting regulatory barriers to the development
of beneficial new technologies. This is particularly important
when these services and technologies can facilitate access
to the benefits of the National Information Infrastructure.
At the same time, we should not amend our rules to favor
new technologies and services simply because they are new.
Any difference in the regulatory treatment of new technologies
and services must have a sound basis in public policy.
18. We also believe that it is desirable to avoid measures that could reduce the level of nontraffic sensitive (NTS) local loop costs now recovered through flat charges. We find that the implementation of SLCs has produced significant benefits, leading to lower interstate toll rates, and increased economic efficiency.(n34) SLCs have also reduced the untargeted support flowsbetween high and low volume toll users.(n35) Any reduction in SLC revenues will tend to increase interstate toll rates because lower SLC revenues will cause LECs to seek to recover additional revenues through the per minute CCL charge.(n36) We also believe that policies that would appear to reduce dramatically SLC charges to large business customers, but not to residential customers, must be carefully examined.(n37)
19. Resolution of the issues in this proceeding should
also take into account competitive developments in the
interstate access market, and the accompanying need to
identify and reduce unnecessary support flows, and reexamine
rate structures predicated on an exclusively monopoly market
structure. We believe that this is necessary in order
to ensure fair competition and preserve universal service.
20. In light of competitive developments in the interstate
access market, rule changes that could result in lower
SLC revenues and higher CCL rates, thus potentially increasing
support flows, must be carefully examined. To the extent
that the LECs do not recover interstate NTS local loop
costs through SLCs, they recover these costs through the
CCL charge. The per minute CCL charge paid by IXCs and
reflected in their interstate toll rates forces high volume
residential and business toll users to pay charges that
exceed the local loop costs they impose on the network.
This creates incentives for high volume toll customers
to use competitors even when the LEC would be the most
efficient access provider. Increasingly, IXCs and large
business customers have alternatives to use of LEC facilities
for the origination and termination of interstate traffic,
particularly in major urban business centers. In such
areas, they can avoidsupport flows inherent in the current
access charge rate structure, including the CCL charge.
In the long run, inefficient bypass of the LEC networks
by high volume toll customers could threaten to undermine
the support flows that foster universal service.
22. There are also intermediate options. For example,
the number of SLCs to be applied to ISDN facilities could
be based on a ratio of the average LEC cost of providing
a derived channel service, such as a BRI or PRI ISDN connection,
to the average cost of providing an ordinary local loop
or T-1 connection, including the line or trunk card costs
in both cases. Under this option, a PRI customer would,
for example, pay six SLCs if the average LEC cost of providing
an ISDN T-1 connection, including line cards, is six times
the average cost of providing an ordinary T-1 facility.
It would also be possible to apply one SLC for every two
derived channels, an option that would reduce by 50 percent
the SLC revenues that would be generated under the current
requirement that one SLC be assessed for each derived channel.
23. Another set of options would focus on the increasingly
competitive interstate access market in determining how
to compute the SLC to be paid by customers of derived channel
services. One possibility is to combine a reduction in
the currently required level of SLC charges for derived
channel services with a small increase in the per-channel
SLC for all local loops. Another option involves giving
the LECs some flexibility in setting SLC rates for derived
channel services, but modifying the price cap rules so
that any reduction in SLC flat rate recovery does not increase
the CCL rate.
25. Widespread use of ISDN and other derived channel services under these approaches, which apply far fewer SLCs to such services than the current requirement, could reduce multiline business SLC revenues over time. This would tend to increase interstate toll rates as a result of increases in LEC CCL rates. This approach also appears potentially inconsistent with the general objective of reducing the untargeted support flows intrinsic to the existing per minute CCL charge.(n38) In addition, applying SLCs based on the number of copper pairs used by a customer is not feasible if a customer's local loop is provided over coaxial or fiber optic cable. These options would also result in inconsistent treatment when the same derived channel technology is used to provide local loops in other service configurations.(n39)
26. Moreover, these options lead to lower SLCs for
large business customers than for residential and single
line business customers. At present, residential and single
line business customers generally pay monthly SLCs of $3.50
per line, while multiline business customers pay monthly
SLCs of up to $6.00 per line. Under the per-facility approach,
large business customers taking a derived channel service
that provides 24 channels, such as ISDN PRI, would pay
a single SLC capped at $6.00 per month, which equates to
$.25 per month per voice grade equivalent channel. Residential
and single line small business customers taking ISDN BRI
would pay a single SLC capped at $3.50 per month, which
equates to $1.75 per month for each voice grade equivalent
channel. In contrast, a residential subscriber with a
single standard local exchange line pays up to $3.50 per
month in SLCs. Moreover, a household with a second standard
local exchange or "teen" line pays $7.00 per month in SLCs
even though LECs typically run two copper pairs to each
residence, and thus theuse of a second line does not require
additional plant investment.
28. While we do not have data on the relationship between
the cost of providing ISDN and non-ISDN local loops and
T-1 facilities, we anticipate that this approach would
produce SLC revenues for ISDN and other derived channel
services that are higher than those produced by applying
a single SLC per facility, but well below those produced
by charging a SLC for each derived channel. If this is
correct, this approach would affect demand for derived
channel services less than a SLC for each derived channel.
At the same time, it would not have the same potential
to reduce multiline business SLC revenues and to cause
increased interstate toll rates as the per facility approach
has. As a result, this approach would also be more consistent
with the objective of reducing the untargeted support flows
intrinsic to the CCL charge in light of competitive developments
in the interstate access market.
29. This approach does appear to depart from the averaging
reflected in SLCs to date. Subject to the $3.50 and $6.00
caps, SLCs are based on averaged loop costs within each
study area, and the Commission has not previously established
lower SLCs for a particular service or group of customers
based on the lower cost of serving them. While the maximum
SLCs for residential and single line business customers
are lower than the maximum SLCs for multiline business
customers, this difference in the rate cap is not based
on cost differences.(n41) This approach also includes the cost
of the line cards in developing the cost relationship between
ISDN connections and non-ISDN connections even though line
cards are treated as switching, not local loop facilities
for jurisdictional separations and Part 69 cost allocationpurposes.
In light of the additional local switching costs incurred
to provide ISDN, however, additional cost recovery, even
if accomplished through a different rate element, may be
30. Reducing SLCs for derived channel connections
to 50 percent of the level required by the current rules
is another intermediate option between the per-facility
and per-derived channel approaches. Under this approach,
the LECs would charge one SLC for every two derived channels.(n42)
Like the previous option, this approach would foster the
growth of derived channel services to a greater extent
than applying a SLC to each derived channel. This option
would also raise substantially less concern about increasing
interstate toll rates than the per-facility approach.
It is also more consistent with the long term need to reduce
the support flows intrinsic to the current CCL charge in
light of increasing competition.
33. One such option would be to permit the LECs to impose
a reduced number of SLCs for derived channel services,
accompanied by a small increase in SLC rates. For example,
the current caps on SLCs could be increased by $.25 per
month for all subscribers. This approach would encourage
the development of ISDN and other derived channel services
by reducing cost recovery from derived channel services.
At the same time, it would lessen or prevent any potential
reduction in SLC revenues that could lead to higher interstate
34. A second approach that would prevent adverse consequences
from a potential reduction in multiline business SLC revenues
would be to permit, but not require, the LECs to apply
fewer SLCs for derived channel services than the current
rules require, but to adjust the price caps rules to prevent
this from leading to an increase in CCL rates. This approach
would permit the LECs to lower SLCs for derived channel
services in order to encourage their development, but would
prevent a reduction in SLC revenues from causing an increase
in CCL charges and putting upward pressure on interstate
36. In addition, we note that it would be helpful if
interested parties provide us with specific information
concerning the perceived elasticity of demand for ISDN
services, the various ISDN service options available in
the marketplace, the total intrastate charges for each
of these service options, as well as the advantages and
disadvantages of alternative service and equipment configurations
that offer communications capabilities comparable to those
of ISDN. Moreover, certain of the options for applying
SLCs under our Part 69 access charge rules described above
would use a definition of the term "line"that differs from
the current separations definition in Part 36.(n44) We seek
comment on whether we should initiate the process of considering
conforming separations changes through a referral to a
Joint Board in the event that we adopt such an approach.
In light of competitive developments in the interstate
access market, interested parties may also wish to take
this opportunity to comment more generally on the need
for additional changes to the way carriers can recover
the interstate assignment of local loop costs and local
switching or other other costs that the parties view as
William F. Caton
I. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 II. Background A. ISDN and Other Derived Channel Technology and Services. . . . . . . . . 2 B. Subscriber Line Charges . . . . . . . . . . . . . . . . . . . . . . . . 6 C. Recent Decisions on SLCs for ISDN. . . . . . . . . . . . . . . . . . 10 D. Competition. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 III. Discussion A. Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 B. Analytical Framework. . . . . . . . . . . . . . . . . . . . . . . . . 16 C. Options 1. Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 2. The Per-Facility Approach . . . . . . . . . . . . . . . . . . . . 24 3. Intermediate Options . . . . . . . . . . . . . . . . . . . . . . . 27 4. The Per-Derived Channel Approach . . . . . . . . . . . . . . . . . 31 5. Additional Options . . . . . . . . . . . . . . . . . . . . . . . . 32 6. Request for Comments. . . . . . . . . . . . . . . . . . . . . . . 35 IV. Ex Parte Presentations . . . . . . . . . . . . . . . . . . . . . . . . 37 V. Regulatory Flexibility Analysis. . . . . . . . . . . . . . . . . . . . . 38 V. Comment Filing Dates. . . . . . . . . . . . . . . . . . . . . . . . . . 39 V. Ordering Clauses. . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
Footnote 1 For purposes of this Notice, a "single facility" refers, for example, to both ordinary residential local loops and T-1 facilities, although residential local loops generally consist of a single pair of twisted copper wires, and a T-1 facility generally consists of two twisted copper pairs. The equivalent of up to 24 voice-grade channels can be provided over a T-1 facility using multiplexing equipment. See generally, William L. Schweber, Electronic Communications Systems at 685, Prentice-Hall, Inc. 1991.
Footnote 2 A local loop connects a subscriber's home or business to the local telephone company central office.
Footnote 3 It is possible to serve an ISDN customer through a distant ISDN-equipped central office if the local central office is not equipped with ISDN. Bell Atlantic Emergency Petition for Waiver at n.11, filed February 10, 1995.
Footnote 4 A subscriber loop interface circuit or line card in the local switch "is responsible for providing signals to the loop, sensing loop activity, and sending control signals to the phone at the end of the loop." William L. Schweber, Electronic Communications Systems at 492, Prentice-Hall, Inc. 1991. A trunk card performs similar functions for trunks, which generally connect LEC offices.
Footnote 5 The ISDN CPE used with an ordinary copper pair local loop can cost between $250 and $1,000. The ISDN CPE used with a T-1 connection can cost up to $15,000. See Bell Atlantic Petition at n.13.
Footnote 6 All of the Bell Operating Companies (BOCs) and some of the larger independent telephone companies offer ISDN in at least part of their service territory.
Footnote 7 The two voice-grade-equivalent channels, which are called the bearer or B channels, can be used for voice local exchange service or for data transmission at speeds up to 64 kbps. The third channel is a 16 kbps data channel, called the delta or D channel, which is used for signalling and packet data services. Bell Atlantic Petition at n.8.
Footnote 8 In the case of PRI, the 23 B channels and the D channel can transmit voice or data at speeds up to 64 kbps. When a customer has more than one PRI connection at a given location, the B channels can share a single D channel. This permits the customer to use all 24 channels on the subsequent connections directly for their own communications needs. Id. at n.8.
Footnote 9 Memorandum Opinion and Order, NYNEX Telephone Companies Revisions to Tariff F.C.C. No.1, 7 FCC Rcd 7938 n.11 (Com. Car. Bur. 1992) (Rejection Order), aff'd, 10 FCC Rcd 2247 (1995).
Footnote 10 Id.
Footnote 11 The LECs charge a single SLC for each of these channels. See, e.g., Rejection Order at para. 2.
Footnote 12 Third Report and Order, MTS and WATS Market Structure, CC Docket No. 78-72, 93 FCC 2d 241 (1983), recon., Memorandum Opinion and Order, CC Docket No. 78-72, 97 FCC 2d 682 (1983) (First Recon. Order), further recon., Memorandum Opinion and Order, CC Docket No. 78-72, 97 FCC 2d 834 (1984), aff'd in part, National Association of Regulatory Utility Commissioners v. FCC, 737 F.2d 1095 (1984).
Although SLCs were initially adopted in the Third Report
and Order in the MTS and WATS Market Structure proceeding,
supra n.12, the issue of SLCs for residential and single
line business customers was subsequently referred to a
Joint Board composed of Federal Communications Commission
and state regulatory Commissioners for a development of
recommendations. The Commission implemented SLCs for residential
and single line business customers based on the Joint Board's
recommendations. Decision and Order, MTS and WATS Market
Structure, CC Docket No. 78-72 and Amendment of Part 67
of the Commission's Rules, CC Docket No. 80-286, 50 Fed.
Reg. 939 (1985); Report and Order, MTS and WATS Market
Structure, CC Docket No.78-72 and Amendment of Part 67
of the Commission's Rules, CC Docket No. 80-286, 2 FCC
Rcd 2953 (1987).
The interstate allocation of common line costs is 25% of the cost of local loop plant unless the LEC is eligible for compensation from the Universal Service Fund. In that case, the allocation is higher. 47 C.F.R. § 36.154(c)& Subpart F-Universal Service Fund.
Footnote 14 47 C.F.R. § 69.105.
Footnote 15 The SLC for multiline business customers is capped at $6.00 per line per month or the full interstate assignment of common line costs per month, whichever is less. 47 C.F.R. § 69.104(c)&(d).
Footnote 16 Decision and Order, MTS and WATS Market Structure, CC Docket No. 78-72, and Amendment of Part 67 of the Commission's Rules, CC Docket No. 80-286, 50 Fed. Reg. 939 (1985).
Footnote 17 Residential and single line business SLCs are capped at $3.50 per line per month or the full interstate assignment of common line costs per line per month, whichever is less. 47 C.F. R. §§ 69.104 & 69.203 (a).
Footnote 18 Decision and Order, MTS and WATS Market Structure, CC Docket No. 78-72 and Amendment of Part 69 of the Commission's Rules, CC Docket No. 80-286, 50 Fed. Reg. 939 (1985) (initial subscriber line charge waiver). Decision and Order, MTS and WATS Market Structure, CC Docket No. 78-72 and Amendment of Part 69 of the Commission's Rules, CC Docket No. 80-286, 51 Fed. Reg. 1371 (1986) (lifeline assistance), aff'd on recon., 1 FCC Rcd 431 (1986), modified, Report and Order, MTS and WATS Market Structure, CC Docket No. 78-72 and Amendment of Part 69 of the Commission's Rules, CC Docket No. 80-286, 2 FCC Rcd 2953, 2955-56 & 2957-59 (1987), recon., 3 FCC Rcd 4552-53. Report and Order, MTS and WATS Market Structure, CC Docket No. 78-72 and Amendment of Part 69 of the Commission's Rules, CC Docket No. 80-286, 2FCC Rcd 2953 (1987) (Link Up America assistance), modified, Decision and Order, MTS and WATS Market Structure, Link Up America, and Amendment of Part 36 of the Commission's Rules, CC Docket No. 88-341, 4 FCC Rcd 3634 (1989).
Footnote 19 The reductions in interstate toll rates also stimulated demand for these services, increasing the number of switched access minutes over which the nontraffic sensitive CCL costs were recovered. This permitted additional CCL rate reductions.
Footnote 20 Monitoring Report, CC Docket No. 87-339, at Table 5.5, May 1994.
Footnote 21 Rejection Order, 7 FCC Rcd 7938 para. 2( 1992). See para. 5 supra for a description of these services.
Footnote 22 Rejection Order, 7 FCC Rcd 7938 (CCB 1992). Section 69.104 of the Commission's rules, 47 C.F.R. § 69.104, provides for a monthly per line charge for end users that subscribe to local exchange service, stating that such charges shall be assessed for each line between the customer's premises and a Class 5 Office that is or may be used for local exchange transmissions.
Footnote 23 Rejection Order at para. 5, citing 47 C.F.R. Part 36 Glossary (emphasis added).
Footnote 24 Id.
Footnote 25 Rejection Order at para. 5.
Footnote 26 Order on Reconsideration, NYNEX Telephone Companies Revisions to Tariff F.C.C. No.1, Transmittal No. 116, FCC No. 94-356, released January 11, 1995, 10 FCC Rcd 2247 (1995).
Footnote 27 Id. at para 26.
Footnote 28 Teleport is owned by Telecommunications, Inc. (TCI) (29.9%), Cox Cable Communications (30.1%), Comcast Corp. (20%), and Continental Cablevision (20%). Telephone Interview with Rodger Cawley, Director Public Affairs, TCG (Teleport), May 23, 1995.
Footnote 29 "Fiber Deployment Update - End of Year 1993," Industry Analysis Division, Common Carrier Bureau, FCC (1994) at 31-41.
Footnote 30 Hyperion Telecommunications, Inc., a competitive access provider operating in a number of states, is owned almost entirely by Adelphia Cable. See also "The Man who Would Save NY for NYNEX," New York Times, p. D1, April 3, 1995; "NCTA Targets Arizona, Missouri for Local Competition" Telecommunications Reports, at 13, March 20, 1995.
Footnote 31 For example, AT&T now offers local exchange service on a limited resale basis in the Rochester Telephone Company service area. Rochester Telephone Company Petition for Waivers to Implement Its Open Market Plan, FCC 95-96, released March 7, 1995. AT&T has also announced an intention to enter the local exchange market in certain other areas. "AT&T Applies for Local Service Authority in Two States," Telecommunications Reports, pp.35-36, May 8, 1995. MCI recently announced plans to build local access facilities. "The Man Who Would Save NY for NYNEX," New York Times, p. D1, April 3, 1995.
Footnote 32 Report and Order and Notice of Proposed Rulemaking, Expanded Interconnection with Local Telephone Company Facilities, CC Docket No. 91-141, 7 FCC Rcd 7369 (1992)(Special Access Expanded Interconnection Order), recon., 8 FCC Rcd 127 (1992), vacated in part and remandedsub nom. Bell Atlantic v. FCC, No. 92-1619(D.C. Cir., June 10, 1994), on remand, Memorandum Opinion and Order, FCC 94-190, released July 25, 1994 (Remand Order); Second Report and Order and Third Notice of Proposed Rulemaking, Expanded Interconnection with Local Telephone Company Facilities, CC Docket No. 91-141, 8 FCC Rcd 7374 (1993) (Switched Transport Expanded Interconnection Order), pet. for review pending sub nom. Bell Atlantic v. FCC, No. 93-1743 (D.C. Cir., filed Nov. 12, 1993.)
Footnote 33 For purposes of this Notice, "support flows" refer the to the benefits a particular group of customers receives when they pay less than the LEC cost of providing the services they use, while other customers pay more than the cost of the services thatthey receive. See n.35 infra.
Footnote 34 As previously discussed, SLCs resulted in substantial reductions in interstate toll rates. This resulted in increaseddemand for interstate toll services without commensurate increases in LEC costs since local loop costs are not traffic sensitive.
Footnote 35 Recovery of the interstate allocation of local loop costs through per minute toll charges forced high volume toll users to pay much more than the cost of the local loop facilities that they used. At the same time, low volume toll users failed to pay the full cost of their local loop facilities, regardless of their ability to do so.
Footnote 36 The Price Cap rules establish a single Price Cap Index (PCI) for the Common Line Category, which includes the SLC and CCL rate elements. Thus, a forecast decrease in SLC revenue permits the LEC to increase CCL rates, absent other offsetting factors. 47 U.S.C. § 61.46(d).
Footnote 37 See infra para. 26.
Footnote 38 See para. 18 & n.35 supra.
Footnote 39 For example, in its tariff, NYNEX proposed to continue to apply SLCs on a per-derived-channel basis when a single T-1 facility was used to provide more than one service to one customer. Rejection Order at para.6; Reconsideration Order at para 19.
Footnote 40 The need to obtain and analyze cost data may represent a drawback to this approach.
Footnote 41 For an explanation of how SLCs are calculated see para. 8 supra.
Footnote 42 This could also be done by applying 50 percent of the otherwise applicable SLC charge to each derived channel.
Footnote 42 See, paras. 18 & 20 supra.
Footnote 43 See para. 5 supra.
Footnote 44 See para. 11 supra.
Footnote 45 See generally, Sections 1.1202, 1.1203 and 1.1206(a) of the Commission's rules, 47 C.F.R. §§ 1.1202, 1.1203 & 1.1206(a).
Footnote 46 5 U.S.C. §§ 601-12.